The IRS launch campaign to audit U.S. distributors that buy goods from related parties in other countries.
Matthew Wall of MDW submitted comments to the OECD’s latest revision of 2016 Discussion Draft for the guidance on profit splits.
MDW explained the Department of Finance Canada issued draft amendments for the Income Tax Act to include Country-by-Country Reporting as part of the OECD BEPS measures.
Matthew Wall submitted an expert report to legal counsel on transfer pricing for an appeal in the Tax Court of Canada.
MDW explained the Federal Budget will give the CRA $444 million over five years to crack down on tax evasion and tax avoidance with an expected return of $2.5 billion of additional revenue.
MDW explained the CRA’s latest Transfer Pricing Memo (TPM-17) says government assistance should not be used to lower the fee for related party services using the cost plus a mark-up.
Carswell’s Tax Hyperion published “Warning: Tax Authorities are Auditing Inter-Company Loans and Other Financial Transactions” by Matthew Wall.
Carswell’s Tax Hyperion published “Why Transfer Pricing Disputes are on the Rise for Companies of All Sizes” by Matthew Wall.
MDW explained the final revisions to the OECD Guidelines for Chapter VI on Intangibles states the legal owner of intangibles does not have the right to all of the intangible profits.
MDW explained taxpayers with a “cash box” in a low or no-tax jurisdiction must review the 2015 OECD Guidelines and might need to revise their corporate structure, transactions between related parties, or both, to mitigate the risk of a dispute.